@taoj , my understanding of this s" special rule " and for re-patriation of citizens and Green Card holders is that instead of treating these persons as pure Non-Resident Aliens under section 871, there si the possibility of treating them under section 877 A unless 871 yields more taxes due. and considering tac treaty benefits . I am not very clear as to benefit of this special rule. However, I suggest the taxpayer ( whom had given up US citizenship or GreenCard and within a three year period renounced the earlier decision or entered the country again as a GreenCard holder ) to read through both section 871 and 877A in conjunction with the applicable tax treaty. I say this every thing depends on the exact facts and circumstances of the particular tax payer.
